Tax Matters Blog

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Articles/Publications

Stay in the know with Andreozzi Bluestein LLP

IRS Relaxes Bona Fide Residency Rules in the Wake of Hurricanes Irma and Maria

By: Heather L. Marello, Esq. In the wake of recent hurricanes that devastated Puerto Rico and the U.S. Virgin Islands, IRS released Notice 2017-56, Physical Presence of Certain Individuals in the ...

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IRS Delinquent 1120F Campaign – Are You Prepared?

BY: LOU CARLOW The IRS has identified the failure to file Forms 1120-F as the most recent front for its enhanced campaign to enforce compliance.  This campaign sends a clear message to foreign ...

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How U.S. Foreign Information Reporting applies to Your Cross Border Holdings

by Michael J. Tedesco As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S.  Failing to file ...

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Andreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues

Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special ...

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The Threat of Parallel Investigations: When Civil Isn’t Civil

While at one time, the IRS would discontinue a civil examination when it began a criminal investigation of a taxpayer, it is now the IRS’s policy in certain situations to conduct simultaneous ...

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Law Creates New Due Dates for FBAR and Other Tax and Informational Returns

On Friday, July 31, 2015, President Obama signed H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law.  In addition to temporarily extending funding ...

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Taxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report

To combat money laundering and evasion of U.S. income obligations through the use of offshore accounts, Congress imposed a requirement on all United States taxpayers to annually file a Report of ...

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FEDERAL COURT APPROVES U.S. GOVERNMENT ISSUANCE OF JOHN DOE SUMMONSES

A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons¹ to several entities in the U.S who utilized the services of Sovereign ...

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RECENT REVISIONS TO THE IRS OFFSHORE VOLUNTARY DISCLOSURE PROGRAMS

Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not yet come forward to ...

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Matrimonial Law and the IRS

Federal tax law can impact virtually every area of legal practice.  For example, in debtor/credit law, certain property is protected from enforced collection, such as a 401K, IRA or homestead ...

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IRS Makes Significant Changes to the Offshore Voluntary Disclosure Program and Streamlined Voluntary Disclosure Program

On June 18, 2014, the Internal Revenue Service (“IRS”) announced significant changes to the offshore voluntary disclosure programs. As part of the announcement, the IRS has expanded the 2012 ...

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Aragona Trust: Passive Activity Losses, the Material Participation Exception, and the Medicare Tax

Generally speaking, most taxpayers, including individuals and trusts, are denied the use of their passive activity losses and credits to offset ordinary income under the passive activity loss ...

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Tax Anxiety – Good News & Bad News

With the upcoming hype surrounding taxes as April 15th approaches, anxiety increases for those in tax trouble. A significant number of people have been contacted by the taxing authorities about ...

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The 11th Circuit Court of Appeals Reverses Tax Court Ruling on Intervention in USVI Cases

On February 20, 2014, the United States Court of Appeals for the Eleventh Circuit released an opinion allowing the Government of the United States Virgin Islands (“USVI”) to intervene in three ...

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Department of Justice Reminds Swiss Banks That Time is Running Out to Participate in a Non-Prosecution Agreement

In a November 5, 2013 post in The Justice Blog, the United States Department of Justice (DOJ) Tax Division issued a reminder to Swiss Banks that their time is running out to enter into a ...

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Liens and Levies

By: Gregory D. Verdibello, Esq. Once a taxpayer’s liability has been formally recorded on the books and records of the Internal Revenue Service (“IRS”), the IRS may use one of its collection ...

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Offers in Compromise: A Guide

By: Royston Mendonza Overview Very simply, an Offer in Compromise (“Offer”) is where a Taxpayer “offers” a sum of money to the Internal Revenue Service (“IRS”) to “compromise” a tax ...

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There’s Always Something (the IRS) There to Remind Me

Dionne Warwick Bankruptcy Case Seeks to Discharge Taxes By: Daniel Brown “Wishin’ and Hopin’”[2] to discharge more than $10.2 million in taxes, Dionne Warwick filed a Chapter 7 personal ...

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The New York State Department of Taxation and Finance Grants Relief for Non-Filers

By: Gregory Verdibello Unfiled returns can create financial and emotional stress, and can cause criminal issues for many people. It seems that more and more people are failing to file their returns ...

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Shedding Some Light on the PFIC Regime

By: Kenneth A. Grossberg Today, United States investors in foreign corporations often find themselves with an unknown or unexpected problem.  In particular, investors in mutual funds organized ...

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Federal Court Authorizes IRS to Issue “John Doe” Summons to UBS

The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) continue to actively seek information about U.S. taxpayers with interests in foreign accounts.  The IRS and the DOJ sought ...

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Internal Revenue Service Offers New Guidance on FBAR and OVDP Procedures

The IRS has announced new procedures to aid voluntary disclosures by taxpayers with undisclosed foreign accounts. The new procedures follow the IRS’ January 9, 2012 announcement of the 2012 ...

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Randall Andreozzi Co-Authors Article on FBARS

Individuals with a financial interest in bank accounts or certain foreign financial accounts must report these accounts, if their cumulative value exceeds a threshold amount. Form TD F 90-22.1, ...

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HSBC Bank Accounts Targets by IRS Offshore Activity Efforts

On April 7, 2011, a United States District Court issued an order permitting the IRS to serve John Doe summonses requesting information from HSBC Bank regarding U.S. taxpayers who hold HSBC accounts ...

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IRS Launches Compliance Initiative on Estate & Gift Tax

The IRS has recently launched a compliance initiative aimed at identifying taxpayers with potential estate or gift tax liabilities or related compliance issues. As part of this initiative, the IRS ...

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IRS Offers New Voluntary Disclosure Program for Offshore Bank Account Holders

On February 8, 2011 IRS Commissioner Douglas Shulman announced a new voluntary disclosure program forU.S. taxpayers with offshore financial accounts. The Offshore Voluntary Disclosure Initiative ...

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WikiLeaks May Impact US Offshore Account Holders

The website, WikiLeaks, has become a controversial news phenomenon. WikiLeaks publishes secret, private, and classified information primarily with respect to government practices. Its recent ...

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President Obama Signs Small Business Act Providing Significant Tax Benefits

On September 27th President Obama signed the Small Business Jobs Act of 2010  into law. The Act contains several tax provisions that may prove beneficial to many small businesses and their owners. ...

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Government Plans to Subpoena Accountants Engaged in Kovel Arrangements

Attorneys are not always fluent in accounting.  Thus, accountants are often retained by a client’s attorney to assist them in rendering advice to the client.  In the seminal case United ...

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Foreign Bank Account Reporting FBAR and the IRS Voluntary Compliance Initiative of 2009

On March 23, the IRS announced its voluntary compliance initiative to encourage disclosure of foreign bank account details, such as previously undisclosed foreign financial accounts and entities. The ...

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